SecProbe.io

January 5, 2012
 Via E-mail

Mr. Kevin P. Riley Executive Vice President and Chief Financial Officer Berkshire Hills Bancorp, Inc. 24 North Street Pittsfield, Massachusetts 01201
Re: Berkshire Hills Bancorp, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2010
Filed March 16, 2011 Form 10-Q for the Quarterly Period Ended September 30, 2011 Filed November 9, 2011 File No. 000-51584

Dear Mr. Riley:

We have reviewed your supplemental response filed December 19, 2011 and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  Where we have requested changes in  future filings, please include a draft of your
proposed disclosures that clearly identifies new or revised disclosu res.  If you do not believe our
comments apply to your facts and circumstances or  do not believe an amendment is appropriate,
please tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, including the draf t of your proposed disclosures, we may have
additional comments.               Form 10-Q for the quarterly period ended September 30, 2011

Note 7. Loans, page 21
 1. We note your response to comment 8 in our lett er dated November 22, 2011 that a number of
commercial loan relationships were restructured into A/B loans, with the B loan charged off
and the A loan restructured to  a current market interest ra te supported by established debt
service payment streams and that in 2010 many of  these restructured A loans were removed
from the TDR classification based on the market  interest rate and proven payment history.

Mr. Kevin P. Riley
Berkshire Hills Bancorp, Inc. January 5, 2012 Page 2

a. For each loan, please tell us the relevant facts and circumstances related to the
restructuring.  Specifically tell us the type  of modifications made (A note/B note, term
extension, etc.).
b. For each loan, please tell us in detail how you determined that the interest rate was
greater than the rate that you were willing to accept at the ti me of the restructuring for a
new loan with comparable risk.  Refer to ASC 310-40-50-2.  Speci fically discuss how
you determined the rate you were willing to accep t at the time of the restructuring for a
new loan with comparable risk.
c. Please tell us if each loan would have met your underwriting standards for a new loan at
the time it was restructured.
d. Please clarify how you measure credit impairment  on these loans.  If you do not measure
impairment using the guidance in ASC 310- 10, please tell us how you considered the
guidance in ASC 310-40-50-5.
e. Please revise future flings to provide a roll forward of your TDR’s for each period
presented.

You may contact Benjamin Phi ppen, Staff Accountant, at (2 02) 551-3697 or me at (202)
551-3492 with any other questions.
Sincerely,
  /s/ John P. Nolan
        John P. Nolan
Senior Assistant Chief Accountant